Publicly-Owned Treatment Works

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Overview

VVV RTR Cost Basis
# Respondents
# Responses
Respondent Burden
Agency Burden
Capital & O&M

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Sheet 1: VVV RTR Cost Basis

Two existing, industrial (Group 1) facilities will now be required to have a pretreatment program and meet a HAP fraction emitted limit of 0.08.

These facilities are currently in compliance with the pretreatment program and the HAP fraction limit (0.08). Therefore, there are no Capital & O&M costs associated with the rule amendments.

No burden associated with the pretreatment requirements are anticipated under the RTR rule amendments as these sources currently report under the CWA.

Four existing, non-industrial (Group 2) facilities will now be required to have a pretreatment program and meet a HAP fraction emitted limit of 0.08.

Each of these facilities is currently in compliance with the new requirements based on their responses to the ICR. Therefore, there are no Capital & O&M costs associated with the rule amendments.

No burden associated with the pretreatment requirements are anticipated under the RTR rule amendments as these sources currently report under the CWA.

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Sheet 2: # Respondents

Number of Respondents
	Respondents That Submit Reports		Respondents That Do Not Submit Any Reports
	(A)	(B)	(C)	(D)	(E)
Year	Number of New Respondents1	Number of Existing Respondents	Number of Existing Respondents that keep records but do not submit reports	Number of Existing Respondents That Are Also New Respondents	Number of Respondents
					(E=A+B+C-D)
1	6	0	0	0	6
2	0	6	0	0	6
3	0	6	0	0	6
Average	2	4	0	0	6
1 New respondents include 6 existing sources with new reporting requirements under the amended rule.

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Sheet 3: # Responses

Total Annual Responses
(A) Information Collection Activity	(B) Number of Respondents	(C) Number of Responses	(D) Number of Existing Respondents That Keep Records But Do Not Submit Reports	(E) Total Annual Responses E=(BxC)+D
Initial notification	0	1	0	0
Notification of compliance status	6	1	0	6
Request for extension of compliance	0	1	0	0
Notification of special compliance requirements	0	1	0	0
Notification of initial performance test	0	1	0	0
Additional notification requirements for sources with CMS	0	1	0	0
Notification of adjustments to time periods	0	1	0	0
Notification of changes to information provided	0	1	0	0
Initial performance test report	0	1	0	0
Inspection and monitoring plan	0	1	0	0
Annual report	0	1	0	0
Excess emissions report	0	1	0	0
Initial report on compliance approach	6	1	0	6
			Total	12
CMS - Continuous Monitoring System			hrs/response:	8.25

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Sheet 4: Respondent Burden

Table 1: Annual Respondent Burden and Cost – NESHAP for Publicly Owned Treatment Works (40 CFR Part 63, Subpart VVV) (2016 RTR)										Source Type	No.
										Existing	0
				Labor Rates:	$108.61	$143.26	$52.88			New (other sectors)	6	(4 existing/non-industrial sources now subject to rqmts, 2 existing industrial sources subject to new rqmts)
Burden item	A	B	C	D	E	F	G	H
	Person-hours per occurrence	Annual occurrences per respondent	Person-hours per respondent per year (AxB)	Respondents per year a	Technical hours per year (CxD)	Management hours per year (Ex0.05)	Clerical hours per year (Ex0.10)	Annual cost ($) b		ERG Notes:
1. Applications	N/A
2. Surveys and studies	N/A
3. Reporting requirements
A. Familiarization with rule requirements c	0.5	1	1	6	3	0.2	0.3	363
B. Required activities
Initial notificiation	2	1	2	0	0	0	0	0
Notification of compliance status d	2	1	2	6	12	1	1	1,453		63.1590(a)(1) - will now require compliance status notifications for 4 existing non-industrial (Group 2) POTWs and 2 existing industrial (Group 1) POTWs.
C. Create information	See 3B
D. Gather existing information	See 3B
E. Write reports
Request for extension of compliance	2	1	2	0	0	0	0	0
Notification of special compliance requirements	2	1	2	0	0	0	0	0
Notification of initial performance test d	N/A
Additional notification requirements for source with CMS	2	1	2	0	0	0	0	0
Notification of adjustments to time periods	2	1	2	0	0	0	0	0
Notification of changes to information provided	2	1	2	0	0	0	0	0
Initial performance test report	N/A
Inspection and monitoring plan	N/A
Annual report	1	2	2	0	0	0.0	0.0	0
Excess emissions report	2	1	2	0	0	0	0	0
HAP fraction emitted report	4	1	4	6	24	1	2	2,905		63.1590(a)(2) - will now require all 6 existing sources to report their HAP fraction emitted annually.
Initial report on compliance approach	4	1	4	6	24	1	2	2,905		63.1590(f) - will now require all 6 existing sources to develop a compliance demonstration plan to meet the fraction emitted limit.
Reporting Subtotal					72			7,627
4. Recordkeeping
A. Familiarization with rule requirements	See 3A
B. Plan activities	See 3E
C. Implement activities	See 3E
D. Develop record system	See 3E
E. Time to enter information
Records of annual inspections	2	1	2	0	0	0	0	0
Records of inspections, defects, and repair delays	2	1	2	0	0	0	0	0
Methods and data used to determine compliance with fraction emitted limits d	2	1	4	6	24	1	2	2,905		63.1589(b) - will now require all 6 existing sources to prepare and maintain records to meet the fraction emitted limit.
F. Time to transmit or disclose information	N/A
G. Time to train personnel	N/A
H. Time for audits	N/A
Recordkeeping Subtotal					27			2,905
TOTAL ANNUAL BURDEN AND COST (ROUNDED) e					99			10,530
TOTAL ANNUAL CAPITAL AND O&M COST (SEE SECTION 6(b)(iii))								0
GRAND TOTAL (LABOR, CAPITAL, AND O&M) e								10,530
CMS - Continuous Monitoring System
N/A - Not Applicable
Assumptions:
a EPA estimates six existing sources will now be subject to reporting requirements. We do not expect any new sources will become subject to the rule over the next three years.
b This ICR uses the following labor rates: $108.61 (technical), $143.26 (managerial), and $52.88 (clerical). These rates are from the United States Department of Labor, Bureau of Labor Statistics, September 2016, “Table 2. Civilian Workers, by occupational and industry group.” The rates are from column 1, “Total compensation.” They have been increased by 110 percent to account for the benefit packages available to those employed by private industry. http://www.bls.gov/news.release/ecec.t02.htm
c This burden represents the time existing respondents spend familiarizing themselves with the rule amendments.
d The proposed rule revisions now require additional recordkeeping and reporting from 4 existing, non-industrial POTWs and from 2 existing, industrial POTWs.
e Totals have been rounded to three significant digits. Figures may not add exactly due to rounding.

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Sheet 5: Agency Burden

Table 2: Average Annual EPA Burden and Cost – NESHAP for Publicly Owned Treatment Works (40 CFR Part 63, Subpart VVV) (2016 RTR)
				Labor Rates:	$47.62	$64.16	$25.76
Burden item	A	B	C	D	E	F	G	H
	EPA person-hours per occurrence	Annual occurrences per respondent	EPA person-hours per respondent per year (AxB)	Respondents per year a	Technical hours per year (CxD)	Management hours per year (Ex0.05)	Clerical hours per year (Ex0.10)	Annual cost ($) b
Initial performance test c	N/A
Repeat initial performance test c	N/A
Report review
Initial notification	2	1	2	0	0	0	0	0
Notification of compliance status c	2	1	2	6	12	1	1	641		63.1590(a)(1) - will now require compliance status notifications for 4 existing non-industrial (Group 2) POTWs and 2 existing industrial (Group 1) POTWs.
Request for extension of compliance	0.5	1	1	0	0	0	0	0
Notification of special compliance requirements	2	1	2	0	0	0	0	0
Notification of initial performance test c	2	1	2	0	0	0	0	0
Additional notification requirements for sources with CMS	2	1	2	0	0	0	0	0
Notification of adjustments to time periods	2	1	2	0	0	0	0	0
Notification of changes to information provided	2	1	2	0	0	0	0	0
Initial performance test report c	N/A
Inspection and monitoring plan c	N/A
Annual report	1	2	2	0	0	0.0	0.0	0.00
Excess emissions report	N/A
HAP fraction emitted report	2	1	2	6	12	1	1	641		63.1590(a)(2) - will now require all 6 existing sources to report their HAP fraction emitted annually.
Initial report on compliance approach	2	1	2	6	12	1	1	641		63.1590(f) - will now require all 6 existing sources to develop a compliance demonstration plan to meet the fraction emitted limit.
TOTAL ANNUAL BURDEN AND COST (ROUNDED) d					41			1,922
CMS - Continuous Monitoring System
N/A - Not Applicable
Assumptions:
a EPA estimates an average of six existing sources will be subject to the standard. We do not expect any new sources will become subject to the rule over the next three years.
b This ICR uses the following labor rates: $47.60 (technical), $64.16 (managerial), and $25.76 (clerical). These rates are from the Office of Personnel Management (OPM), 2016 General Schedule, which excludes locality rates of pay. The rates have been increased by 60 percent to account for the benefit packages available to government employees.
c Existing sources are now subject to rule emission limits and related performance testing (if applicable), plan development, and reporting activities.
d Totals have been rounded to three significant digits. Figures may not add exactly due to rounding.

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Sheet 6: Capital & O&M

No Capital/Startup or O&M costs for this ICR.